Hey,
Have you actually heard this happening, or are you just theorizing?
There is risk of digital clipping, but it’s not from the output voltage. It’s from upsampling. There’s a good paper on it from Benchmark Media somewhere about what happens.
Imagine a 44.1kHz/16 bit recording. Let’s say it’s a simple sine wave and the original samples happen to reach maximum. At the top, you could have two samples at peak output in a recording. Not an uncommon thing as many mastering engineers push the max sample to the peak digital output to ensure the recording has plenty of dynamic range. Depending on the precise timing, you could have two adjacent peak signals or one very close and the other at peak.
Anyway, if you convert from 44.1/16 to 88.1/16 with linear interpolation there will be no issue, but most upsampling (thanks to cheap compute power) use something like a French curve to interpolate. Now our new samples can exceed maximum digital output. That is true digital clipping. The solution is to slightly reduce the signal when upsampling. Not a horrible thing when you also increase the bit depth before doing so.